EU AI Act · Article 50 in force · marking deadline 2 December 2026
EU AI Act · Article 50(1) · Chat widgets

Smartsupp and the EU AI Act: does your chat widget tell people it's AI?

In force since 2 Aug 2026Fines up to €15M / 3% turnoverLast reviewed July 2026

Smartsupp's Mira is an AI shopping assistant built for ecommerce, and its setup is explicit about humanizing the bot: you type a name, choose a gender, and pick an avatar from a gallery, and that identity displays in the widget header and next to every message Mira sends. That's an unusually direct version of the Article 50(1) tension, the product's own onboarding flow asks you to give an AI a human name and a gendered face before it ever talks to a visitor.

The rule itself is short. Article 50(1) of the EU AI Act requires AI systems that interact directly with people to be designed so users know they're dealing with AI, no later than the first interaction, in a clear and distinguishable way. The exception for cases where it's "obvious" is narrow: a natural-language customer-service bot doesn't qualify just because it has a robot icon. A line in your terms of service doesn't satisfy it either. And it's easy to enforce, because a regulator can open your site and start a chat.

Who's on the hook? Responsibility is split: Smartsupp carries provider-side duties for the system itself, but how the widget is configured and presented on your site is your deployment. If the disclosure setting exists but isn't enabled, or the notice is hidden, that gap is yours.

Where the disclosure lives in Smartsupp

In a typical Smartsupp setup, the surfaces that can carry (or fail to carry) the AI disclosure are:

Your Smartsupp disclosure checklist

Keep proof. On a complaint, an authority will want to see that the disclosure was there and how it was designed. Keep timestamped screenshots of the first-interaction state, your widget configuration, and a record of when each was last changed. That evidence file is the difference between "we comply" and "we can show we complied."

Watch out for

Smartsupp built Mira's setup around making the assistant feel like a real team member, a named, gendered, illustrated character greeting shoppers in the widget header. That's effective ecommerce UX and a near-textbook case of what Article 50(1)'s "obvious from context" exception was not written to cover: a human-presenting figure that never says, anywhere, that it's AI.

Note: vendor interfaces and setting names change. This page describes where disclosure surfaces typically live in Smartsupp as of July 2026; verify the exact toggles in your own Smartsupp workspace and against Smartsupp's current documentation.

Common questions

Mira comes with a friendly designed avatar by default, doesn't that style already read as "obviously a bot"?

Not reliably. Illustrated or cartoon-style avatars still read as a character with a name and gender, not necessarily as "this is AI", the safer assumption is that avatar style alone doesn't do the disclosure work, so keep an explicit line in the greeting.

Mira hands off to us when she's unsure, do we need to relabel anything at that point?

Yes, briefly, let the visitor know a human has joined. It doesn't need to be dramatic, just clear enough that they know who they're talking to now versus a moment ago.

Check it in one scan. DisclosureProof opens your site the way a regulator would, triggers your Smartsupp widget, and records whether the AI disclosure appears, with timestamped evidence either way. Run the free scan →